that body is accredited as a community development finance institution under this Schedule at the time the investment is made (see Part 2);

the investment is a qualifying investment (see Part 3); and

the general conditions of Part 4 are satisfied.

F49it makes a loan (whether secured or unsecured) to the body, or

an issue of securities of or shares in the body, for which F49it has subscribed, is made to F49it.

where the loan agreement authorises the body to draw down amounts of the loan over a period of time, the loan is treated as made at the time when the first amount is drawn down.

the CDFI receives from the investor, on the investment date, the full amount of the loan, or

if the loan agreement authorises the CDFI to draw down amounts of the loan over a period of time, the end of that period is not later than 18 months after the investment date.

the repayment during the first two years of the five year period of any of the loan capital advanced in those two years,

the repayment during the third year of that period of more than 25% of the loan capital outstanding at the end of those two years,

the repayment before the end of the fourth year of that period of more than 50% of that loan capital, or

the repayment before the end of that period of more than 75% of that loan capital.

is imposed by reason only of the commercial risks to which the investor is exposed as lender under that agreement, and

is no more likely to be breached than any obligation that might reasonably have been agreed in respect of the loan in the absence of this Schedule.

subscribed for wholly in cash, and

fully paid for on the investment date.

any present or future right to be redeemed within the five year period, or

any present or future right to be converted into or exchanged for a loan which is, or securities, shares or other rights which are, redeemable within that period.

subscribed for wholly in cash, and

fully paid up on the investment date.

Shares are not fully paid up for the purposes of paragraph (b) if there is any undertaking to pay cash to the CDFI at a future date in connection with the acquisition of the shares.

any present or future right to be redeemed during the five year period, or

any present or future right to be converted into or exchanged for a loan which is, or securities, shares or other rights which are, redeemable within that period.

those investments, and

any investments to which sub-paragraph (2A) applies,

have been made in the CDFI in the accreditation period, and

in respect of which the CDFI has issued tax relief certificates under section 348 of ITA 2007 (which makes in relation to income tax provision corresponding to that made by this paragraph).

£10 million if the CDFI is accredited for the period as a retail community development finance institution (see section 340(8) of ITA 2007 as applied by paragraph 4), and

£20 million in any other case.

if the investment consists of securities or shares, the amount subscribed for them.

under which the investment is made, or

made, before the investor makes the investment, in relation to or in connection with the making of the investment,

by means of the possession of voting power in the CDFI, or

by virtue of any powers conferred by the constitution of, or any other document regulating, the CDFI,

any rights or powers that the investor is entitled to acquire at a future date or will, at a future date, become entitled to acquire, and

any rights or powers which another person holds on behalf of the investor or may be required to exercise, by direction, on F52its behalf.

purports to be provided by the investor by way of loan capital, and

is accounted for as partners’ capital in the accounts of the partnership.

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

eligible for relief in respect of the investment (see paragraph 1(1)).

5% of the invested amount in respect of that loan or those securities or shares for the period, and

the amount which reduces the investor’s liability to zero.

the accounting period in which the investment date falls, and

each of the accounting periods in which the subsequent four anniversaries of that date fall.

it appears to the investor that the conditions for the relief are for the time being satisfied, and

it has received a tax relief certificate (see paragraph 12) relating to the investment from the CDFI,

paragraph 22 (loans: no claim after disposal or excessive repayments or receipts of value);

paragraph 23 (securities or shares: no claim after disposal or excessive receipts of value);

paragraph 24 (loss of accreditation by CDFI);

paragraph 25 (accreditation of the investor).

for the F56... accounting period in which the investment date falls, the average capital balance for the first year of the five year period;

for the F56... accounting period in which the first anniversary of the investment date falls, the average capital balance for the second year of the five year period;

the investor disposes of the whole or any part of the loan before the qualifying date relating to F25that period,

at any time after the investment is made but before that qualifying date, the amount of the capital outstanding on the loan is reduced to nil, or

before that qualifying date, paragraphs (a) and (b) of paragraph 30(1) (repayments of loan in five year period exceeding permitted limits) apply in relation to the investment (whether by virtue of paragraph 31 (receipts of value treated as repayments) or otherwise).

For the purposes of paragraph (a) any repayment of the loan is to be disregarded.

beginning when the investment is made, and

ending immediately before the qualifying date relating to the F14... accounting period.

for the relevant F41... accounting period, or

for any later F41... accounting period.

where the relevant time falls within the first year of the five year period, the F42... accounting period in which the investment date fell, and

in any other case, the F43... period in which fell the last anniversary of that date before the relevant time (or, if the relevant time itself falls on an anniversary of the investment date, the F43... period in which that anniversary falls).

where the relevant time falls within the first year of the five year period, the accounting period in which the investment date fell, and

in any other case, the period in which fell the last anniversary of that date before the relevant time (or, if the relevant time itself falls on an anniversary of the investment date, the period in which that anniversary falls).

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

references to the relief attributable to any loan, securities or shares in respect of an accounting period shall be read as references to the reduction made in the investor’s liability to corporation tax for that period that is attributed to that loan, or those securities or shares, in accordance with this paragraph.

This is subject to the provisions of Part 6 for the withdrawal or reduction of relief.

where the reduction is obtained by reason of one loan, or securities or shares comprised in one issue, the amount of the tax reduction shall be attributed to that loan or those securities or shares, and

a proportionate part of any amount attributed to the original shares, in respect of F11an accounting period, immediately before the bonus shares are issued shall be attributed to each of the shares in the holding comprising the original shares and the bonus shares, in respect of F12that period, and

is subsequently found not to have been due, or

falls to be withdrawn or reduced under this Part.

the investor disposes of the whole of the investment, otherwise than by way of a permitted disposal, or

the investor disposes of a part of the investment,

a full or partial repayment of the loan shall not be treated as giving rise to a disposal.

the investor disposes of the whole or any part of the investment (“the former investment”) within the five year period,

the CDFI has not ceased to be accredited before the disposal, and

the disposal does not arise by virtue of an event within paragraph 35(1)(a) (repayment, redemption or repurchase of securities or shares included in the investment).

if it is greater than an amount equal to 5% of the amount or value of the consideration (if any) which the investor receives for the former investment, be reduced by that amount, and

in any other case, be withdrawn.

by way of a bargain made at arm’s length for full consideration, or

a permitted disposal (within the meaning of paragraph 28).

the amount of relief attributable to the former investment (“A”) is less than

the amount (“B”) which is equal to 5% of the invested amount in respect of the former investment for F22that period,

the average capital balance of the loan for the third, fourth or final year of the five year period is less than the permitted balance for the year in question, and

the difference between those balances is not an amount of insignificant value,

at the choice or discretion of the CDFI and not as a direct or indirect consequence of any obligation provided for under the terms of the loan agreement, or

does not exceed £1,000, or

if it exceeds that amount, is insignificant in relation to the average capital balance of the loan for the year of the five year period in question.

paragraph 21 (determination of “invested amount"), and

paragraph 30 (repayments of loan capital),

where the value was received in the first or second year of the period of restriction, at the beginning of that second year, and

where the value was received in a later year of that period, at the beginning of the year in question.

does not exceed £1,000, or

if it exceeds that amount, is insignificant in relation to the average capital balance of the loan for the year of the period of restriction in which the value is received.

“the average capital balance” of the loan for a year is the mean of the daily balances of capital outstanding during the year (disregarding the receipt of value in question), and

any value received in the first year of the period of restriction shall be treated as received at the beginning of the second year of that period.

the investor receives any value (other than insignificant value) from the CDFI during the period of restriction,

the investment or a part of it is held by the investor at the time the value is received and has been held by F28the investor, as sole beneficial owner, continuously since the investment was made (“the continuing investment”),

the receipt is wholly or partly in excess of the permitted level of receipts in respect of the continuing investment, and

the amount of that excess (“the excess”) is not an amount of insignificant value,

any amount of value is received by the investor (disregarding any amounts of insignificant value) in the first three years of the period of restriction, or

value is received (“the relevant receipt”) by the investor from the CDFI at any time during the period of restriction relating to the investment,

the investor has received from the CDFI one or more receipts of insignificant value at a time or times during that period but not later than the time of the relevant receipt, and

the aggregate amount of the value of the receipts within paragraphs (a) and (b) is not an amount of insignificant value,

does not exceed £1,000, or

if it exceeds that amount, is insignificant in relation to the relevant amount.

if the relevant receipt is received in the first or second year of the period of restriction, the average capital balance of the loan for the second year of that period, and

if the relevant receipt is received in a later year, the average capital balance of the loan for the year in question.

the average capital balance of the loan for a year is the mean of the daily balances of capital outstanding during the year, and

the relevant receipt and any receipts within sub-paragraph (1)(b) shall be disregarded when calculating the average capital balance for the year in question.

if the relevant receipt is received in the first year of the period of restriction, the amount subscribed for the securities or shares, and

repays, redeems or repurchases any securities or shares included in the investment;

releases or waives any liability of the investor to the CDFI or discharges, or undertakes to discharge, any liability of the investor to a third person;

makes a loan or advance to the investor which has not been repaid in full before the investment is made;

disposes of an asset to the investor for no consideration or for a consideration which is or the value of which is less than the market value of the asset;

acquires an asset from the investor for a consideration which is or the value of which is more than the market value of the asset; or

makes a payment to the investor other than a qualifying payment.

the amount of any debt incurred by the investor to the CDFI (other than an ordinary trade debt), and

the amount of any debt due from the investor to a third person which has been assigned to the CDFI.

references to a debt or liability do not, in relation to a person, include references to any debt or liability which would be discharged by the making by that person of a qualifying payment;

references to a benefit or facility do not include references to any benefit or facility provided in circumstances such that, if a payment had been made of an amount equal to its value, that payment would have been a qualifying payment; and

any reference to a payment or disposal to a person includes a reference to a payment or disposal made to that person indirectly or to his order or for his benefit.

In paragraphs (a) to (c) references to “a person” include references to any person who, at any time in the period of restriction in question, is connected with that person, whether or not he is so connected at the material time.

the investor makes two or more investments in the CDFI (being investments in relation to which the investor is eligible for and claims relief), and

the investor receives value (other than value within paragraph 35(1)(a)) which falls within the periods of restriction relating to two or more of those investments.

A is the appropriate amount in respect of the investment in question, and

B is the aggregate of that amount and the appropriate amount or amounts in respect of the other investment or investments.

if the value is received in the first or second year of the period of restriction, the average capital balance of the loan for the second year of that period, and

if the value is received in a later year, the average capital balance of the loan for the year in question.

the average capital balance of the loan for a year is the mean of the daily balances of capital outstanding during the year, and

the receipt of value shall be disregarded when calculating the average capital balance for the year in question.

if the value is received in the first year of the period of restriction, the amount subscribed for the securities or shares, and

the investor receives any value (other than insignificant value) from the CDFI during the period of restriction, and

the investment or a part of it is held by the investor at the time the value is received and has been held by F32the investor, as sole beneficial owner, continuously since the investment was made (“the continuing investment”),

any F34... accounting period ending on or after the anniversary of the investment date immediately preceding the receipt of value, or

if the value was received on an anniversary of the investment date, any F34... accounting period ending on or after that anniversary.

does not exceed £1,000, or

if it exceeds that amount, is insignificant in relation to the amount subscribed by the investor for the securities or shares comprising the continuing investment.

the investor has obtained relief in respect of the investment, and

an event occurs by reason of which relief attributable to the investment for any F47... accounting period falls to be withdrawn or reduced by virtue of paragraph 28, 29, 30 or 32,

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

F48... the end of the period of 12 months beginning with the end of the accounting period in which the event occurred.

the investor is required to give a notice by virtue of the receipt of value by a person connected with the investor (see paragraph 39), and

the end of the period of 60 days beginning when the investor comes to know of that event is later than the final notice date under sub-paragraph (2),

by the Secretary of State to the Inland Revenue for the purpose of assisting the Inland Revenue to discharge their functions under the F74Corporation Tax Acts so far as relating to matters arising under this Schedule, or

by the Inland Revenue to the Secretary of State for the purpose of assisting the Secretary of State to discharge his functions under this Schedule.

loans made by or to, or disposed of by, a nominee for a person shall be treated as made by or to, or disposed of by, that person;

securities or shares subscribed for by, issued to, acquired or held by or disposed of by a nominee for a person shall be treated as subscribed for by, issued to, acquired or held by or disposed of by that person.

references (however expressed) to an issue of securities of any body are to such securities of that body as carry the same rights and are issued under the same terms and on the same day, and

references (however expressed) to an issue of shares in any body are to such shares in that body as are of the same class and issued on the same day.

the investor disposes of part of a holding of securities or shares (“the holding”), and

the holding includes securities or shares to which relief is attributable in respect of one or more F38... accounting periods that have been held continuously by the investor from the time they were issued until the disposal,

any number of securities of a company carrying the same rights and issued under the same terms held by the investor in the same capacity, growing or diminishing as securities carrying those rights and issued under those terms are acquired or disposed of, or

any number of shares in a company of the same class held by the investor in the same capacity, growing or diminishing as shares of that class are acquired or disposed of.

to which relief is attributable, and

which have been held by the investor continuously from the time they were issued until the time of disposal,

the reference to section 127 includes a reference to that section as it is applied by virtue of any enactment relating to chargeable gains, and

“original shares” and “new holding” have the same meaning as in section 127 or (as the case may be) that section as applied by virtue of the enactment in question.

would be treated as exchanging for other securities or shares by virtue of section 136 of the 1992 Act, or

would be so treated but for section 137(1) of the 1992 Act (which restricts section 136 of that Act to bona fide reconstructions).

F77the investor is deemed, under any provision of the 1992 Act, to have disposed of and immediately reacquired the investment (or part) at any time during the period, or

F77the investor is treated as having disposed of the investment (or part) at any such time, by virtue of paragraph 48(2).

any relative or partner of that person,

the trustee or trustees of any settlement in relation to which that person, or any relative of his (living or dead), is or was a settlor, and

references to relief obtained by the investor in respect of any investment (or part of an investment) include references to relief obtained by the investor in respect of that investment (or part) at any time after the investor has disposed of it, and

references to the withdrawal or reduction of relief obtained by the investor in respect of the investment (or any part of it) include references to the withdrawal or reduction of relief obtained in respect of that investment (or part) at any such time.

references in this Schedule to a condition being satisfied for the time being are to nothing having occurred to prevent its being satisfied, and

references to its continuing to be satisfied are to nothing occurring to prevent its being satisfied.